Based on a June 2026 survey of historic preservation professionals
A June 2026 survey of historic
preservation professionals reveals broad interest in reforming the National
Register of Historic Places (NRHP) nomination process, but also deep skepticism
about whether a "simplified" pathway can actually solve the problems
it aims to address.
The survey, titled
Debating Changes to the
NRHP: A Simplified Nomination Process, drew ten responses from a mix of
state and federal government staff, nonprofit preservation professionals,
academics, and private consultants. While the sample is small, the respondents
represent a range of institutional perspectives — from SHPOs (State Historic
Preservation Offices) to national nonprofits to academia — and their answers
surface a consistent, cautious theme: reform may be worth pursuing, but only if
it is grounded in a much clearer definition of what "simplified"
actually means.
Who Responded
Most respondents identified as
practitioners or professionals in the field (70%), with smaller shares
describing themselves as preservation consultants, regulatory officers or
administrators, and academics. Nonprofit organizations were the most common institutional
affiliation (60%), followed by state and federal government (50% each) and
local government (30%). Geographically, half of respondents described their
work as national in scope, with state, local, and regional practice also
represented — the Mid-Atlantic and South were the most common regions cited.
Is the Current System Failing Underserved Communities?
The survey opened by probing
whether communities lacking technical expertise or financial resources struggle
to protect historically meaningful places, and whether underrepresented groups
remain underrepresented on the National Register. Here, the responses
complicated the survey's own premise. A large majority pushed back on a simple
"yes," with several respondents noting that a National Register
listing does not equal protection, and that technical assistance for
nominations is already available from multiple sources. On the question of
underrepresentation, most respondents avoided a binary answer altogether,
arguing that the answer depends heavily on geography and how
"underrepresented" is defined.
This pattern — resistance to
yes/no framing in favor of nuanced, conditional answers — recurred throughout
the survey and became one of its most notable findings in its own right.
Appetite for Change, With Reservations
Asked directly whether the NRHP
is "long overdue some serious debating," opinion was split, with many
respondents objecting that the question itself was too broad to answer
meaningfully. However, a strong majority (70%) agreed that the preservation
community should start brainstorming and testing novel ideas, even as some
cautioned that many practitioners are already innovating within the current
system.
When asked whether a simplified
process — reduced paperwork, notice requirements, time, and cost — could help
underrepresented communities get a fair hearing, the response was
overwhelmingly skeptical (90% "no"). One respondent pointed out that
property owners in their state already self-prepare nominations at minimal
cost, and that nomination length has grown not because of bureaucratic
requirements, but because owners themselves want fuller histories documented.
Who Should Be Eligible, and What Should Disqualify a Property?
Respondents were more receptive
to specific eligibility criteria than to the concept in the abstract.
Indigenous tribes or tribal organizations were the most frequently cited group
that should have access to a simplified pathway (50%), followed by neighborhood
associations, sole property owners with income limitations, and 501(c)(3)
organizations (30% each). Several respondents rejected the framing of
"eligibility" altogether, arguing instead that the existing National
Register program already accommodates many of these needs.
On disqualifying factors, no
single issue dominated. Complex property boundaries, subsurface archaeological
concerns, and extensive physical integrity issues were each flagged by 30% of
respondents, but 40% said none of the listed factors should disqualify a
property — suggesting reluctance to build new exclusionary criteria into a
reform meant to be more inclusive.
Half of respondents supported
automatically qualifying properties already listed on a State Register, though
several cautioned that state registers vary too widely in rigor to generalize.
Race, Identity, and Eligibility Categories
When asked which historically
underrepresented or vulnerable groups should be eligible to submit nominations
under a simplified process, Black and African American communities and
Indigenous, Tribal, and Native communities each drew support from 60% of respondents,
with Hispanic/Latino/Chicano communities, LGBTQ+ communities, individuals with
disabilities, and Asian American and Pacific Islander communities each cited by
half. Notably, a handful of respondents rejected the entire premise of
group-based eligibility, with one warning that using such categories risks
"othering" the very communities the reform intends to help.
Technical Standards: Age, Integrity, and Significance
Familiarity with the National
Park Service's existing technical concepts of "age and integrity" and
"significance" was low among respondents — only 20% reported
familiarity with either. Yet among the smaller subset who answered whether
these concepts should remain applicable under a simplified process, the
response was strongly negative: roughly 87% said no in both cases. The two
write-in responses that elaborated on this point converged on the idea that
historic and cultural significance should remain the central test, but that the
criteria need more flexibility — with one respondent cautioning against a
standard so loose that "everything is significant" and therefore
nothing is.
A narrow majority (60%)
supported reducing or simplifying the evidentiary burden for simplified
applications. Among the smaller group who specified how, the most popular
options (each cited by 100% and 75% of that subgroup, respectively) were
streamlined preliminary reviews, pre-established historic contexts,
standardized integrity thresholds, oral testimony via sworn statement, and
delegated sign-offs. Only one respondent supported using AI to help analyze
application data.
Costs, Funding, and Process Mechanics
Opinion was divided on whether
the federal government should cover the cost of additional research required
under a simplified process: half said "partially," with smaller
shares saying "yes" or "no" outright. Respondents were
similarly split on whether applicants should have to disclose funding sources
or face restrictions on funding, with pluralities leaning against new
disclosure or funding restrictions.
Most respondents (80%) did not
think simplified applications should be reviewed on a different timeframe than
standard nominations, though two who did suggest a workable range said two to
six months would be reasonable. Similarly, a majority did not support creating
an alternative to NPS Form 10-900, the standard nomination form — though many
said they lacked enough information about the form's actual requirements to
judge.
Public Participation and Next Steps
Sixty percent of respondents
believed a simplified process could encourage greater public participation in
preservation, though several qualified their answers by noting how vague the
underlying proposal still is. Overwhelmingly — 90% of respondents — agreed that
the concept needs broader discussion within the preservation community before
any formal proposal reaches the Secretary of the Interior. Suggested venues for
that discussion included the National Alliance of Preservation Commissions
(NAPC) forum, the National Trust for Historic Preservation's annual conference,
meetings of the National Conference of State Historic Preservation Officers
(NCSHPO) and the National Association of Tribal Historic Preservation Officers
(NATHPO), and outreach to identity-based preservation groups. One respondent
urged organizers to look beyond preservation-specific circles entirely, to
fields like landscape and cemetery conservation and community development,
noting: "Part of the problem today is we only talk among ourselves."
Survey Design: A Recurring Complaint
A significant thread running
through the open-ended responses was frustration with the survey's own framing.
Several respondents noted that many questions hinged on an undefined term —
"the simplified nomination process" — making it difficult to answer
meaningfully. As one respondent put it, forcing complex, conditional issues
into yes/no answers "introduces preferences and prejudices that cloud
understanding." Despite this, 70% of respondents felt they were able to
express their feedback adequately, and half felt they understood the issues and
proposals well, at least in part.
Asked how often they'd want to
participate in a survey like this going forward, 60% said "never,"
with the remainder split between "very often,"
"occasionally," and "not very often" — a result that likely
reflects survey fatigue as much as disengagement from the underlying issue.
Closing Thoughts from Respondents
The survey's final open-ended
question drew four substantive responses that, taken together, capture the
field's overall posture toward reform:
●
One respondent argued that a listing carries real legal
and environmental weight, so any simplified nomination would still need to meet
the bar for NRHP criteria — and suggested that funding context statements for
underrepresented groups may be a more effective use of resources than
simplifying the form itself.
●
Another raised concern about creating a
"two-tiered system when the problem is the system itself," proposing
instead that reform efforts focus on improving the existing multiple-property
documentation framework and the determination-of-eligibility process, alongside
a serious conversation about what "integrity" means as a preservation
standard.
●
A third respondent was emphatic that any simplification
"cannot be political or financial," nor "electronic or
AI-related," and argued that meaningful reform depends on greater
communication with local communities — a lesson they felt the preservation
field should have already learned from the COVID-19 pandemic.
●
A fourth respondent, planning to retire this year,
simply expressed interest in following the conversation further.
Takeaways
Across nearly every question,
this small but experienced group of preservation professionals showed real
appetite for examining how the NRHP nomination process could better serve
underrepresented communities and reduce unnecessary friction. But that appetite
was consistently paired with wariness about vague proposals, concern about
creating parallel review tracks, and a strong preference for grounding any
changes in the existing determination-of-eligibility framework rather than
building an entirely separate process. If there is a mandate here, it is less
"simplify the paperwork" and more "clarify the proposal, then
let the field weigh in."
This analysis is based on a
survey conducted in June 2026 and should be read as a
snapshot of engaged practitioner opinion rather than a statistically
representative sample of the preservation field.
